Intel response to ACMA Consultation on

Spectrum for broadband in the millimetre wave bands

  1. What disposition should the ACMA adopt in progressing possible 5G mmWave bands? Is a traditional approach appropriate, where Australia would wait until there were clear signs of a harmonised, widespread ecosystem developing in a band before it was seriously considered domestically? Or should a more proactive approach be adopted that would potentially make bands available very early in a more speculative manner? What are the benefits and risks to each approach?

WRC-19 Agenda Item 1.13 is studying candidate frequency bands for IMT between 24.25 and 86GHz, as part of the WRC-19 preparation process.The ITU-R is expected to complete relevant sharing and coexistence studies by mid-2018 and identify the global harmonized bands for IMT in WRC-19. In addition, leading countries are already beginning to take steps to make mmWave spectrum available for 5G in advance of WRC-19. For example, the United States has already permittedterrestrial 5G use in the 27.5-28.35 GHz band and 37-40 GHz frequency range. Similarly, China, Japan, Korea, and Europe are all progressing their 5G spectrum plans ahead of WRC-19. It is clear that mmWave bands will become a key part of 5G spectrum and that certain bands are becoming prioritized.

We believe it is now appropriate for AMCA to quickly take steps towards making the key mmWave bands available in order to facilitate the benefits of timely access to 5G in Australia. In particular, spectrum within the 26/28 GHz and 37-43.5 GHz radio tuning ranges are developing strong support as prioritized bands in some countries for 5G deployment or trials. The industry is moving quickly to build 5G products to support these tuning ranges. Similarly, the 57-71 GHz frequency range is likely to be used for unlicensed services. Therefore, ACMA could make spectrum available within these radio tuning ranges with very low risk. Based upon the decisions in leading countries as well as the current status of WRC-19 studies, making spectrum available in other mmWave bands very early would pose more risk.

  1. When, or under what circumstances, would it be appropriate for potential 5GmmWave bands to progress beyond monitoring in the ACMA’s mobile broadband work program?

Given the strong support in leading 5G countries as well as progress under WRC-19 agenda item 1.13 studies, Intel believes it would be appropriate to rapidly progress spectrum within the 26/28 GHz and 37-43 GHz radio tuning ranges beyond monitoring, moving through initial investigation to preliminary replanning). It should be noted that mobile industry is already developing products targeting 3GPP Release 15, which will be finalized by mid-2018 with the following bands as high priority:

26.5-29.5 GHz (TDD)

24.25-29.5 GHz (TDD)

37-40 GHz (TDD)

  1. What bands are the most mature in terms of possible early moves on 5GmmWave bands?

Within the candidate bands in WRC-19 AI1.13,Intel believes 24.25-27.5 GHz (hereafter 26 GHz) and 37 – 43.5 GHz (hereafter 39GHz) are most desirable and present the chance to achieve global harmonization. In particular, spectrum within the 26GHz band benefits from having a suitable radio tuning range in which it is possible to capitalize on initial 5G deployments in leading markets in the 28 GHz band. Similarly, equipment being developed to support the 37-40 GHz band means spectrum within the 37-43.5 GHz band could benefit from a suitable radio tuning range.

In addition, the 27.5-29.5 GHz (28 GHz) band (not being considered under WRC-19 Agenda Item 1.13) has been used in the first 5G trials and is now moving towards initial deployments by operators in countries including the US, Korea, Japan. We believe it is important for ACMA when developing its strategic roadmap for 5G spectrum planning to take into account the benefits from early ecosystem being developed for the 28 GHz band in other regions. Noting that majority of ITU-R TG5/1 studies indicate feasibility of sharing between Mobile Service and Fixed Satellite Service (FSS) in the FSS uplink bands, and that the 26GHz band is directly adjacent to the 28 GHz band and has a 1 GHz of overlap (26.5-27.5 GHz) with the 28 GHz band that could be taken advantage of for early 5G deployments, implementing a wide tuning-range, as being defined by 3GPP, creates the possibility for globally harmonised equipment so as to enable 5G commercial deployment in fast way through leverage the existing product ecosystem.

Intel has developed 28GHz and 39GHz RFIC. Further details can be found below.

  1. What is the relative priority of investigation of mmWave bands versus other potential mobile broadband bands below 6 GHz?

Intel believes 5G use cases and applications will require access to various spectrum in low (<1GHz ), mid (< 6 GHz) and high (e.g. mmW bands) frequency bands to meet the different requirements of enhanced mobile broadband (eMBB), ultra-reliable and low latency communications (uRLLC) and massive machine type communications (mMTC). The different types of spectrum will support the different business needs and applications regarding coverage, throughput, latency, density etc.

Each spectrum range has specific characteristics that make it suitable for certain deployment scenarios. For example, the low frequency band spectrum has very good propagation characteristics that make it suitable for large area coverage but it also has limited capacity due to lack of available spectrum and component design considerations. The mid-band spectrum provides the type of coverage more suitable for urban/suburban deployments with increased capacity. The high-band spectrum is more limited in coverage, but could provide very high capacity due to the amount of spectrum potentially available at these frequencies and the possibility of using high-gain antenna arrays.

There is no single frequency range that will address all 5G requirements.Given the diversity of future applications, we believe spectrum in bands below 6GHz and mmWave bands are both very important. Therefore, we recommend that policymakers make spectrumin low bands (<1 GHz), mid bands (<6GHz) and high bands (mmWave)available for 5G in a timely manner.

  1. Are there any specific regulatory changes that would be required to facilitate and support satellite services in the context of 5G?

WRC-19 agenda item 1.13 only considers the terrestrial component of IMT. We are unaware of any work to date on the satellite component of IMT-2020. We also note that the technical performance requirements of 5G, as developed by ITU-R, are such that fulfilment of some, if not all, by a satellite communication system seem to be very difficult, and in some cases, e.g. latency, impossible.

  1. Should the 26 GHz band be accelerated through the initial investigation stage to the preliminary re-planning stage in the ACMA’s process for consideration of additional spectrum for MBB services? Why/Why not?

Intel strongly encourages ACMA to progress through initial investigation stage to the preliminary re-planning stage in the ACMA’s process in ordert to facilitate access to 5G services in Australia.

A number of countries have already issued regulations or are in consideration to allocate mmWave bands for future mobile broadband use. In the U.S., FCC issued a Report and Order in August 2016 to allocate 28GHz (27.5- 28.35GHz), 37GHz (37-38.6GHz), 39GHz(38.6-40GHz) licensed bands and 64-71GHz unlicensed band for future mobile broadband use. In Europe, EU RSPG recommends the 24.25-27.5 GHz band as a pioneer band for 5G to be harmonized before 2020. The harmonized technical conditions and band plan will be published in an ECC Decision and the results of the studies will be presented in a CEPT Report with a target date for publication June 2018. China prioritized 24.75-27.5GHz and 37.0-42.5GHz two bands in consideration for 5G and assigned these two bands in its China 5G trial. In Korea, the government (MSIP) has assigned 26.5-29.5 GHz band for 5G trials in the 2018 Winter Olympic Games. MSIP issued “K-ICT Spectrum Plan” on Jan, 18, 2017, plans to provide 3GHz bandwidth in the band 26.5-29.5GHz by 2018 when 5G systems are available, at the latest by 2021. MIC Japan has assigned 27.5-29.5 GHz for 5G trials: this is also the candidate band for future commercial use.

In addition, as part of WRC-19 process, 26GHz appears to be one of thebands with the most interest for harmonization under AI1.13.The relevant sharing studies between IMT and other services are being conducted in TG5/1 with the preliminary results of 26GHz showingthat sharing between IMT and FSS is possible. With all this momentum developing globally, we believe ACMA should accelerate the process to progress 26/28 GHz band to the preliminary re-planning stage in order to facilitate timely access to 5G in Australia.

  1. Are there specific issues that may affect the timeframe in which the 26 GHz band could be made available for broadband services?

N/A

  1. Should the 24.25–27 GHz or 24.25–27.5 GHz be made available initially for broadband services?

Yes. In particular, it should be noted that the 26.5-27.5 GHz band is already progressing within 3GPP as part of the 3GPP high priority 26.5-29.5 GHz range which will be supported by initial products. For further information, pls. see answers to Q3 and Q6.

  1. What licensing approach should be used for broadband in the 26 GHz band?

Intel recommends the exclusive license approach for broadband use in 26GHz band.

  1. What geographical areas should be made available for broadband in the 26 GHz band?

Considering the population distribution in Australia, there are multiple geographic area options which could be made available. As these options will ultimately impact the population covered by future 5G services, we recommend exclusive license in high demand areas (Area 3 with 97% population from the 3.6 GHz geographic area option).

  1. Should any other mmWave bands be accelerated through the initial investigation stage to the preliminary re-planning stage in the ACMA’s process for consideration of additional spectrum for MBB services? Why/Why not?

In addition to 26GHz band, Intel recommends ACMA consider 28GHz (27.5- 29.5GHz) and 39GHz (37-43.5GHz) frequency ranges for terrestrial MBB services licensed use, and the 66-71 GHz range for license-exempt use (extending the current 57-66 GHz range) for indoor short range applications as well as outdoor backhaul/fronthaul for support of 5G deployments.

As stated above, 5G trials and pre-commercial tests (e.g. USA, Korea, and Japan) are currently taking place in the 28 GHz band. Due to early-mover countries opening up this band for 5G, the ecosystem is currently developing 5G products for 28 GHz as the first band to be supported. In addition, this band is in the range with the most support in 3GPP for early New Radio (NR) specification development out ofall the bands considered above 6 GHz. In our view, the 28 GHz band is enjoying a de facto harmonization across regions due to the early-mover actions by certain administrations. Therefore, making the 28 GHz band available for 5G deployment would enable Australia to benefit from this early ecosystem development and trial/launch possibilities to help achieving the targets set out for 5G for commercial deployments by 2020. It is also worth noting that majority of ITU-R TG5/1 studies indicate feasibility of sharing between Mobile Service and Fixed Satellite Service (FSS) in the FSS uplink bands.

Spectrum within the 37-43.5GHz frequency range is also likely to be well-harmonized for terrestrial 5G use and should be accelerated to the preliminary replanning stage.In the US, 37-40GHz has already been allocated for mobile broadband. The EU Radio Spectrum Policy Group considers that the band 40.5-43.5 GHz is a viable option for 5G in the longer term. In China,the 37-42.5GHz band has been prioritized for consideration and the band has been assigned for 5G trials. Studies in the ITU-R under WRC-19 agenda item 1.13 are also progressing well. Like the 26GHz/28 GHzfrequency range, the tuning range approach allows different parts of the 37-43.5 GHz frequency range to be considered in different regions, presenting an excellent opportunity for global harmonization and possible implementation across the regions.

As noted above, licence-exempt spectrum, including in the millimetre wave bands, will be a critical component of the 5G landscape. Last year, the U.S. FCC opened the entire 64-71 GHz band for unlicensed operations, which further extended the existing band to allow unlicensed operation between 57GHz and 71GHz. ACMA should consider taking similar action and allow licence-exempt operation in 66-71GHz band to enable AR/VR and other short range applications which need wider channels to support high throughput and low latency as well as providing backhaul/fronthaul opportunity in support of outdoor 5G deployments.

  1. Are there specific issues that may affect the time frame in which other mmWave bands could be made available for broadband services?

N/A

  1. Should part or all of any these bands be considered initially for broadband services?

Yes. Intel recommends to make the parts or all of above bands (26GHz/28GHz and 37-43.5GHz) available for broadband service.Each operator should be able to obtain a minimum of 1GHz continuous mmWave spectrum within these bands for initial 5G deployments.Itis critical for ACMA to ensure sufficient spectrum is made available in a timely manner to support 5G network roll-out.

  1. What licensing approach should be used for broadband in other mmWave bands?

Intel recommends that the exclusive license approach be used for broadband in 26GHz, 28GHz, and 37-43.5GHz band for 5G deployment. As for 66-71GHz band, we recommend the licensed exempt approach, similar to the approach and technical rules applied for 57-66GHz band.

  1. What geographical areas should be made available for broadband in other mmWave bands?

Considering the population distribution in Australia, there are multiple geographic area options which could be made available, which will ultimately impact the population covered by future 5G services. We recommend exclusive license in high demand areas (Area 3 with 97% population from the 3.6 GHz geographic area options).